In re Ashly F

In In re Ashly F. (2014) 225 Cal.App.4th 803, a mother physically abused her children. The Los Angeles County Department of Children and Family Services (DCFS) took them into protective custody and the juvenile court exercised its dependency jurisdiction and ordered them removed from both parents. In its reports for the detention and dispositional hearings, the DCFS stated, without citing any evidence, that it made "reasonable efforts" to prevent the children's removal and there were no "reasonable means" to protect them short of removal. By the dispositional hearing, the mother had admitted her misconduct, completed services, and moved out of the home. The juvenile court ordered the children removed without inquiring what services or alternatives the DCFS considered and rejected before recommending the children's removal. (Ashly F., supra, 225 Cal.App.4th at pp. 805-808.) In reversing, the appellate court concluded the DCFS's assertions that it made "reasonable efforts" and there were no "alternative means" were "perfunctory," the juvenile court simply repeated the DCFS's assertions and that there were reasonable alternatives to removal, including having the mother remain out of the home. (Id. at pp. 809-810.)